Post navigation

The EU Proposes to Act on Perfume

Well, it’s slowly happening. The EU finally seems poised to act, according to a new report by Reuters. The article is entitled “EU Commission proposes tighter regulation of perfume ingredients” and was written by Astrid Wendlandt and Pascale Denis. To be clear, nothing in the article involves anything new. All that is happening now are the first, slow, official steps on events set into motion back in 2012.

In a nutshell, the situation is analogous to a Senate Sub-Committee advisory report going to the Senate who took their time to study it and, finally, after a while, decided it may be time to act on it with actual legislation. Those future legislative enactments have not been passed into law — yet — but things are much closer to that point than they were before. So many people blame IFRA, but the real source of perfume regulation is the EU. Yes, IFRA began all this years and years ago with minor restrictions, but none of them were actual law or quite as wide-sweeping in nature. It has taken the EU to act and make them legal mandates, binding on all who want to sell within their territory.

Dried oakmoss or tree moss.

A few years ago, the EU asked its advisory, scientific body to look into things further. It commissioned the Scientific Committee on Consumer Safety (SCCS) to come up with a report on allergens from perfumery, and that report was published in July 2012. You can read more about the group’s findings and recommendations in my post, 2013, the EU, Reformulations & Perfume Makers’ Secrets. As the new Reuters article summarizes, the SCCS advisory committee made several findings and suggested proposals:

The report called for drastically reducing the use of many natural ingredients found in perfumes, on the basis that 1 to 3 percent of the EU population may be allergic or may become allergic to them.

The recommendations of the report, if adopted by the Commission, threaten to seriously damage the fragrance industry.

The report recommended restricting the concentration of 12 substances – including citral, found in lemon and tangerine oils; coumarin, found in tropical tonka beans; and eugenol, found in rose oil – to 0.01 percent of the finished product.

It also proposed an outright ban on tree moss and oak moss, which provides distinctive woody base notes in Chanel’s No.5 and Dior’s Miss Dior.

Muguet, or Lily of the Valley.

So, what is happening now? Well, the EU Commission is taking its first steps in acting on those suggestions. In essence, “the executive body” (as the Reuters article calls it) is giving its judicial response on the consultants’ 2012 findings. They are planning to follow the 2012 suggestions by proposing specific, upcoming action in a few areas:

a ban of atranaol and chloroatranol, molecules found in oak moss and tree moss, two of the most commonly used raw materials because of their rich, earthy aroma and ability to ‘fix’ a perfume to make it last longer.

ban HICC, a synthetic molecule which replicates the lily of the valley aroma and which has also been widely used by perfume makers.

It is also proposing to significantly lengthen the list of molecules and ingredients perfume makers have to label on the packaging of their products to warn potentially sensitive users.

In short, the EU Commission appears to have flat-out accepted the proposed SCCS suggestion of banning oakmoss, but it is being more cautious with regard to its other suggestion of severely restricting 12 (or more) ingredients. What it is doing instead is what all legislative bodies do when confronted with more inclusive, drastic action: it is going to delay things further by asking for additional reports and investigation. The EU executive Commission has demanded

further research to determine what level of concentration should be used for those 12 ingredients and for another eight. These ingredients represent the spine of about 90 percent of fine fragrances, according to experts.

One reason for the hesitation to take immediate action is the wide-ranging impact that the SCCS’s recommendation would have. IFRA has stated that toying with those 12 ingredients would result in the formulas for over 9,000 perfumes being changed.

Stephen Weller, IFRA photo, via The Scented Salamander.

Speaking of IFRA, in the past, the organisation has pretended that it is the champion of perfumers, and it is only thanks to their actions that oakmoss has not been banned completely. In my piece on Viktoria Minya, the world of a “nose,” and what it’s like to be a perfumer in today’s current EU/IFRA regulated world, I discussed claims made by Stephen Weller, IFRA’s Director of Communications. According to the European blog, The Scented Salamander, Mr. Weller has given a few interviews in France defending his organisation as the supposed savior of certain key ingredients. The Scented Salamander states that Mr. Weller:

makes the particularly salient point in this exchange that without IFRA, a number of perfumery ingredients would have altogether disappeared from the palette of the perfumer as they have come under attack from the European Union and before that pressure groups voicing their concerns…

Weller explains in this new interview with Premium Beauty News how his organism permits a more nuanced approach to the dermatological and allergic risks presented by aromatic materials.

Mr. Weller would have you believe that IFRA is firmly on the perfumers’ side, acting as the sole barrier between the lobbyists who he argues are really at fault, and the total eradication of oakmoss in perfumery. I give my responses to that utterly ridiculous contention in the Viktoria Minya piece, but if anything should show IFRA’s true nature, it’s their reaction to these new 2014 EU developments.

Pierre Sivac, President of IFRA. Source: Cosmeticsbusiness.com

In my favorite part of the recent Reuters article quoted up above, the writers give a very astute, subtle dig at IFRA by first providing their enthusiastic response to the EU executive body, and then, in the next paragraph, explaining who really backs IFRA. Take a look at their exact phrasing:

“We broadly welcome the proposed measures,” said Pierre Sivac, president if the International Fragrance Association, the perfume industry’s self-regulatory body.

Since its creation in 1973, IFRA, which is financed by scent makers such as Givaudan, New York-listed International Flavors & Fragrances and Germany’s Symrise, has restricted natural ingredients for a range of health reasons, from worries about allergies to cancer concerns. [Emphasis added by me.]

Yes, I’m quite sure that Givaudan would welcome the banning of certain natural ingredients and the severe restrictions of 12 others which form the body of 90% of perfumes. I’m quite sure they would….

[UPDATE 2/21/14 — I would like to draw your attention to something that is critical in all this, which is the scientific basis for the regulations in the first place. I’m wholly unable to speak to this with any clear knowledge, but Mark Behnke is most certainly qualified, thanks to an advanced degree in chemistry. He is the former Managing Editor of CaFleureBon who now has his own new site called Colognoisseur, which is where he recently posted an editorial on this issue. There, he writes:

The data used to determine the allergen potential of these molecules is scientifically and statistically unsound. […]The studies these bans and restrictions have been based on were performed one time at one concentration on 25 patients with no controls, positive or negative! This is what makes me shake my head as this is not good scientific practice and the conclusions made are very preliminary and possibly incorrect.

An even bigger flaw is the idea that it’s really only 23 molecules, so what? If these single molecules are restricted and banned it will have a ripple effect throughout many more raw materials. A natural oil is not a single molecule it is a combination of as many as hundreds of individual molecules. Any one of which could be identified as one of the “bad 23” which would then make that natural oil unusable as well. […]

I urge you to read his piece in full.

On the medical front, there is also the information provided in the comments from “Colin,” one of my readers who I believe is a doctor. He talks about the unsoundness of the conclusions in terms of actual medical impact of these allergens, writing

Most people who may be allergic to perfumes or specific scent chemicals have a skin reaction which is not dangerous or life-threatening in any way. A brief review of medical literature reveals only two, yes that is TWO, reported cases of anaphylaxis, which is the severe, life-threatening kind of allergic reaction. One occurred in a health care worker when a patient sprayed her directly in the face with 3 sprays of perfume (I’m completely serious, look it up–Lessenger JE. Occupational acute anaphylactic reaction to assault by perfume spray in the face. J Am Board Fam Pract. 2001;14:137-40). The other occurred when a mother sprayed her 2-month infant in the face with cologne. Neither of these would be considered by anyone to be a customary use of fragrance. Incidentally, in the case of the infant, the cologne contained menthol which was the ingredient the authors suspected to have been the main factor in triggering this response. Is menthol even on the list of ingredients of concern? Should any chemical be regulated if, in the recorded history of humanity, there have been but 2 cases recorded of any anaphylactic reaction and in both cases the perfume was being misused? 3 percent of a population is not a trivial number and would be potentially worthy of public health initiatives if that population were at risk. 2 cases out of the billions and billions of people in the world? Seriously? What a ridiculous waste of time and effort. This is why no reputable major health organizations are militating for any of these regulations. Banning a chemical because some people in the vicinity might get a migraine or the person applying it might get a rash makes little sense.

In short, on both the scientific and medical fronts, the empirical reasons for these regulations are faulty to begin with, never mind where the whole thing may go once the EU actually passes the complete 2014 laws.]

There is a charade playing out in all this, a charade in which we — perfume lovers — are the only losers. Only 1% to 3% of the entire EU suffers from perfume allergies, most of which are quite minor in nature. The European Commission claims that it truly cares about that tiny fraction of its citizenry, but it also firmly insists that it wants to avoid hurting the perfume industry.

“We have to find a way of ensuring security of consumers but also avoid causing damage to the industry,” said a spokesman for Neven Mimica, European Commissioner for Consumer Safety. [Emphasis added by me.]

Avoiding damage to the industry? Forgive me while I snort. In Grasse, the true home of perfumery with its vast fields of natural resources, the producers are so desperate over the SCCS proposal and the effect of any action by the EU that they turned for help to UNESCO. Yes, EU business concerns are turning to help to the bloody UN and to its UNESCO branch, a group better known for assisting Third World countries in dealing with poverty (!!!) or protecting historical treasures.

Source: Palmbeachdailynews.com

You think I’m joking, or that is hyperbole? Consider an article in Euronews from June 2013 discussing the panic amongst the producers of the natural ingredients of perfumery:

There are 2,500 lavender producers in France, covering 20,000 hectars. Grasse is considered by many to be the “capital of perfumes”. It is close to the lavender flower growing regions and home to Robertet, a world leader in natural fragrance production and perfume design. Their 22 branches worldwide turnover 400 million euros a year.

Robertet workers were shocked at the SCCS report with its long list of allergenic substances to declare, limit or ban. To adapt, the French perfume industry would need to pay up to 100 million euros, according to one of the directors. The cost to Robertet would be approximately five million euros.

Francis Thibaudeau, Deputy Manager Fragrance Division, Robertet told euronews: “Allergenic substances are part of perfume products. All the major perfumes would disappear if the SCCS proposals are implemented. Entire branches of perfume-making would be doomed. It would be the death of the industry… we could no longer use jasmine, ylang ylang sandalwood, or bergamotte. Those ingredients and essential natural products would no longer be used…” […][¶]

Meanwhile the tiny village of Montségur-sur-Lauzon is at the very heart of French lavender flower production. The summer air smells different. Fragrant. Here, Kriss, a young distillery manager, and a tractor driver nicknamed Mirabelle share the same fears: the thunderstorm forecast for later today, and the storm brewing over the European Commission’s apparent attempt to limit the use of coumarine, an allergenic substance naturally present in lavender flowers…

Kriss told euronews: “This European law on allergenic substances under discussion would be a catastrophe for all professions dealing with natural raw materials. Such a law would limit the use of those substances on a very low level. 90 percent of existing natural raw materials from plants could not be used any longer. The perfumers would have to change all their formulas…it would be like the debate to ban peanuts in Europe all over again. It’s just stupid.”

Meanwhile, the city of Grasse wants UNESCO to designate its local perfume tradition as World Heritage status. Lavender producers have the same idea: UNESCO should protect them against the ‘bad boys’ of Brussels.[Emphasis added by me.]

Yes, an entire city in the European Union is turning to a UN charitable organisation for help. I think that rather destroys the EU’s pretense of caring so much about the business industry.

Source: Brandsoftheworld.com

That said, if there is a business that the EU wants to help, I’m not sure who it is. It’s too easy to claim that they are in the pocket of Big Business, but such conspiracy theories don’t hold up to a closer examination of the facts. LVMH is practically losing its mind over all this, and it’s certainly bigger, more powerful, and wealthier than either IFF or Symrise, two of the main manufacturers of aromachemicals and fragrance ingredients. The multi-billion dollar, privately owned Chanel corporation also has its panties in a twist, though as my earlier piece on the EU makes clear, L’Oreal (whose fragrances contain a lot of cheap crap) is quietly saying nothing. (No, L’Oreal, I will never, ever forgive you for what you’ve done to YSL fragrances.) Neither is Coty, apparently. (As a side note, IFRA President, Pierre Sivac, was formerly a powerful Coty executive. He also worked at Unilever, another big, beauty industry player that is not exactly known for its prestige fragrances.)

In my earlier piece on the EU, I quoted a discussion on the big split in the perfumery industry:

The proposals have also revealed schisms in the perfume industry – a lack of unity that makes it harder to lobby with one voice.

Brand owners such as Chanel and LVMH and scent-makers such as Coty, L’Oreal, Procter & Gamble, Givaudan and Symrise all have different goals.

LVMH, which owns Dior and Guerlain, and Chanel are lobbying Brussels to protect their perfumes, many of which were created decades ago.

So, again, if one has conspiracy theories about the EU being in the pocket of Big Business, then who is the business group who would actually be helped? Not the Europeans themselves, perhaps. In the opinion of one of the people quoted in the June 2013 Euronews article on Grasse, EU restrictions “would open up the doors of the European market for Indians and Chinese who would profit from European over-regulation and conquer our market shares…” I’m not quite sure how that would happen in Europe, given that anyone buying from the alleged Indian and Chinese profiteers would still have to abide by EU perfume laws, but it would certainly benefit producers and perfume manufacturers in the growing markets outside of Europe.

All these contradictions and competing interests really makes one wonder, yet again, why is all this happening? I honestly don’t know. To me, it simply isn’t logical. As I wrote in the Viktoria Minya piece, I don’t see the EU or manufacturing associations putting restrictions on factories who produce food items or on chefs in restaurants simply because there are some pressure groups who complain about nut allergies. Some of the early EU advisory suggestions (like the ludicrous idea of possibly banning Chanel No. 5 that I’ve talked about in another IFRA/EU post) are akin to shutting down the Eiffel Tower simply because 1%-3% of the EU’s 503.5 million population may have vertigo. (It’s been estimated that “1 to 3 percent of the EU population… are allergic or potentially allergic to natural ingredients contained in fine perfumes, according to a report published in July by the Scientific Committee on Consumer Safety (SCCS), an advisory body for the European Commission.” [Emphasis added.])

If the real concern is truly allergic reactions and not Big Business, then why aren’t warning labels enough? They put such warnings on cigarettes, and on pre-packaged food items that may have been prepared in a factory that had some nuts in it. Are perfumes actually more dangerous to people’s health than cigarettes??! Also, why are perfumes to be regulated with such ingredients as the amount of lavender or citrus oils, but massage oils are left alone? Presumably, that minuscule percentage of EU citizens who have allergic reactions — or just the mere potential thereof — might possibly decide to have a massage one day. Why are those oils fine, but the ones in perfumery — which allergic people can simply avoid using — subject to increasingly Orwellian, draconian measures?

Again, I have to emphasize that the new Reuters article is merely outlining the EU executive body’s first official, judicial response to earlier proposals. It is just like the Senate finally acting on a sub-committee advisory report from a few years before. With the exception of the Lily of the Valley proposal which I hadn’t heard of before or, more likely, had merely forgotten about, all of this has been on the table since 2012. However, now, the EU is finally taking the first slow steps to actually do something about it.

It is only a matter of time. Or perhaps it has already started. As the article notes, “industry sources say major perfume makers have already started modifying their formulas accordingly.”

89 thoughts on “The EU Proposes to Act on Perfume”

Honestly, it’s put me in the filthiest mood all day. The restrictions were always going to happen, and it was always just a question of when, but it doesn’t change how utterly INFURIATING it is given that simple alternatives exist. I mean, honestly, it’s not as though there aren’t *several* more rational, moderated, balanced solutions. For the love of God, why not take the Cigarette Box approach??!!! There is no way that any allergy sufferer will ever be able to convince me that perfumes are more dangerous than cigarettes (or items that are ingested). This is not like throwing the baby out with the bathwater. It’s more akin to maliciously stabbing over 9,000 babies, repeatedly, before throwing them out with the bathwater, while simultaneously ignoring the 800-pound aromachemical elephant in the room.

I’m positively seething right now. If ever there were a time for a stiff double of Laphraoig, I think it would be now.

No, not single-malt scotch, it might have harmful peat-related compounds in it! Please plan to drink highly purified industrial alcohol from now on, for the sake of your health, lest you ingest some aromatic ester that once made the roof of somebody’s mouth burn after drinking straight scotch.
Incidentally, this whole sad charade represents the Prohibition approach: if a substance is too strong for some to handle, take it away from everyone. How did Prohibition turn out, anyway???

Unfortunately the EU have already wielded their draconian powers against the herbal supplements industry, reducing the ability of naturally orientated therapists to help patients get well as quickly. I am one of those therapists.
I am appalled that they are now meddling with the perfume industry and I hope that they are foiled in their endeavours.
A world without Chanel No 5 and other such classic fragrances would be a sadder place.

I agree. Unfortunately, this seems to be the culminations of affairs years and years in the making, going back to 2007 or even a bit earlier. There have been many nails in the perfume coffin from all the restrictions already on the books. At this point, it seems to be a case of the final nail, forever ending the age of perfumery as we know it.

The only surprise here is how quickly the Eurocrats have re-opened a file. I assume that they are short of projects at the moment to waste yet more of both time and money on. The sheer wastage and damage which Brussels causes is unbelievable. It’s a monster out of control.

In the midst of my rage, I had to take a moment to laugh at your very dry, sardonic “I assume that they are short of projects at the moment[.]” Thank you, Iain, for the much needed humour, even if it was very black, grim humour.

This is truly depressing. If similarly draconian measures were taken against far greater public health menaces like sugar and physical indolence and other risk factors for metabolic syndrome, there would be great public consternation, even though these very factors cost billions a year in health expenses and lost productivity in the US and are increasing steadily throughout Europe. But evidently it’s more important to save a tiny fraction of citizens from superficial rashes.

I hear you on the logical focus for their efforts, as well as the depressing nature of all this. I seem to be going through the Kubler-Ross stages of grief, with rage leading to quiet depression. You’re totally right, ingested products like sugar, let alone the ones that cause serious dangers like nuts, are responsible for billions in damages, on the human scale as well as the business one.

I think that’s what gets me so upset about all this: the lack of logical perspective, the absence of common-sense, the insane priorities, and the fact that simple solutions are being completely ignored.

Well, let’s rage rather than sink into a regulation-induced lethargy. It is very discouraging. But idiocy has been with us for a very long time and yet we still have some of the great cheeses that the USDA has tried, over and over, to take away from us for our own good. We still have unpasteurized wines(yes, that’s been proposed), and we can still share our great perfumes with the next generation and whisper “once, you could put these right on your skin if you felt like it. Really. It was your choice.” We will be the fragrant subversives of the future.
Our best hope here is that, for once, some major corporate interests with very deep pockets indeed will be on our side, as well as some very attractive and picturesque cottage industries with high sentimental value as well as dollar power. Perfume Goddess, hear our prayers!

You know, as I was changing my shirt (yes, I really did splutter my drink out all over me after your comment), I thought about something else: tax revenues. You know who is going to benefit the most out of all this? Well, besides Givaudan, IFF, and Symrise, I mean? eBay and PayPal. eBay will become even MORE of a draw for people like us if 9,000+ more perfumes are reformulated. This is not going to be about mere oakmoss and chypres if they are attacking scents with 12+ ingredients in them. The impact is going far beyond things like Chanel No. 5, Mitsouko, and Opium (well, not Opium, because poor Opium is already dead in terms of what it was supposed to be). But things like Lavender, orange peel and more…. ALLLLLLLLLLLLLL those fragrances in all those categories will be limited now to eBay for purchase in their real, original, or almost original scent.

I don’t know the situation with tax dollars or euros and eBay (other than NY or CA eBayers sometimes adding tax on a non-uniform), but I would bet that it is a massive hole in the pocket of actual retailers in the EU. EU tax revenue being lost… how could they not have thought of that side-effect of these regulations?

I think our actual best bet in all this is LVMH. They have greatest combination of wealth, resources, connections, and wide-spread influence to fight on our behalf. More than even Chanel, since LVMH owns so many different companies. Those two companies have the greatest motivation to put their billions to use on their own behalf, so let us indeed pray that they can throw a lot of money at the situation.

You’ve written a very informative article that also exposes much hypocrisy. These restrictions seem ridiculous & the motives are obvious-$$$$.
Is there anything we perfume consumers can do besides sit idly by while we hope that Chanel and LMVH fight the battle?
I”m going to douse myself with Alahine right now to soothe my worried soul-its magic has finally begun to work on me. And to think it may soon be reformulated…sigh

The money thing baffles me though. WHOSE money? Can it really just be about Givaudan profiting given the massive loss of revenue to other companies? If it’s really about Big Business, what about the thousands of producers in Grasse, the super-wealthy LVMH conglomerate, Chanel, Robertet, and lost EU revenue from lost VAT going to eBay sellers? Whatever money Givaudan may make from this would seem to be a drop in the bucket for how much money is lost as a whole.

I mean, when LVMH is freaking out at what will happen and Chanel is panicking that they may forever ban its Chanel No. 5 with all the lost revenues that that would entail, you know that it’s not so simple at just saying $$$$ is the motive. So, what is the real financial picture or motivator? Can it really just be Givaudan and its smaller compatriots, IFF and Symrise? That honestly doesn’t make sense to me. The money doesn’t seem there, as compared to the money on the OTHER side of the picture and the far greater business interests there.

I don’t know, it’s making my head hurt. As to your question of what we can do, nothing, it seems. Pray for LVMH and Chanel to save us, I guess. And start hoarding like those crazy people on the American tv show, Hoarders.

I totally agree – it *does* seem that its not simply $$$ behind it all. But I cant think what else it could be. I’ve gone over it and over it from all angles – economic, political and “medical” – there is a piece of the puzzle missing that I’m not seeing. Usually in situations like this its easy to say “follow the money” because money is usually at the root of it all. This time however, its a murky scenario that feels off kilter.

This whole business makes me sad, oh so sad. And angry too.
I have been thinking/saying the same things: if they don’t ban cigarettes, peanuts, milk, etc. etc. which are all potentially harmful for a small percentage of people (cigarettes are deadly for ALL), then why attack perfumes? Put a warning label on it for heaven’s sake!!!
Meanwhile I’m trying to stock up on some of my favourites and slowly trying to find recent releases that I may like. But this second task seems difficult. Nothing is as good anymore as the good ole perfumes from yonder years, and every other new perfume just reeks of toilet freshener… 😦

Dammit, and I was just getting into the high end scents! This really makes me want to beat someone. I’ll tell you, even people who say that they are allergic to perfumes are not allergic to ME wearing them. I know, I work in the medical field and have seen it firsthand. Plus, I buy body washes that have those natural chemicals in them (I have seen linalool on the product list), so how are those products affected? Oh, the stupidity. The sheer, sheer stupidity.
You must get a list of must try’s before they neuter every scent out there. Then I will hoard like no other.

Dearest Kafka
I agree with almost all you say here, especially in regard to the somewhat insidious role played by IFRA and the aromachemical producers, and, indeed some large perfume makers in lobbying behind the scenes in favour of some of this regulation.
It goes without saying that mass reformulation and the replacement of natural ingredients with artificially synthesised ones will be good business for some…
However, I should point out that UNESCO, headquartered in Paris, is a specialist agency of the UN, rather than a straightforward charitable organisation, and that its aims are far more diverse than simple poverty erradicatication.
Its programme of World Heritage Sites is familiar to many of us in Europe and the status is often used as a measure of ‘ultimate protection’, more moral than legal, when places of exceptional cultural and historical value are in peril. It was for example UNESCO’s intervention that caused initial plans for an ill thought through visitor centre at Stonehenge to be reconsidered and has influenced even the commercially driven Corporation of London, to trim its planning policies so as to add further protection from the encroachment of skyscrapers to the area around the Tower of London.
UNESCO it should also not be forgotten valiantly coordinated the international effort to prevent the compromise of Venice, in layman’s terms ‘it prevented the city from sinking’.
In this context, though it might seem arcane, Byzantine, absurd even that one international body should be used to block the blind acts of cultural destruction of another, it may be the best course of action. In addition it would seem to add force to the campaign to have large sections of the French perfume industry declared ‘a national monument’ (I paraphrase for ease of understanding), thereby exempting it from certain EU regulations.
If perfume, its methods of production and the materials of its creation are, as part of this process, finally recognised as core components of French and by extension global culture, there might even be partly positive outcome in all of this.
My fear, however, is that the forces ranged against the heritage of fine fragrance are simultaneously both too powerful and shady. Not only the ‘industry’ as described above, but, one has reason to believe, certain self-appointed ‘perfume experts’, who have a vested interest in promoting the new as opposed to protecting the old also provide slanted advice to such ‘expert panels of enquiry’ .
Which brings me to my final point, the EU, which is often unfairly used as a fig leaf by cynical national governments too cowardly to push through unpopular reforms themselves, probably does wish to seek some form of compromise here, that is the nature of the organisation. However, Consumer Protection (as the Commissioner’s title suggests) is its core objective and therefore in the absence of dissenting, well-argued reasons to why it should act to the contrary will probably be over cautious in defending what it believes are the best interests of perfume purchasers.
The problem here may be as much who the EU is talking to: crazed ‘health protection’ lobbyists, commercial interests and indifferent scientists, as the organisation itself.
It is therefore just possible that a campaign to gain UNESCO status for Grasse and so confer artistic and cultural value on the olfactory arts, for all that it may seem odd, might be the best position for the friends of perfume to galvanize around. This first step taken, the debate would be reframed, we would not be arguing over a simple matter of consumer protection versus industry interests (which we would be bound to lose) but broader questions of preserving culture and heritage against spurious, or at least hugely over-stated ‘health’ claims.
This is a debate we actually have a chance of winning.
Indeed, given that the EU is equally as active in cultural matters as those of consumer protection and fiercely protective of anything that can be described as definitively ‘European’, I believe it is not a monolith, but an entity that could find itself conflicted over this question.
It may be too late, but ever the optimist, I say man (and woman) the barricades around Grasse in last defence of the art we love.
Yours ever
The Perfumed Dandy

No, of course, you’re right about UNESCO’s World Heritage focus, and it is certainly one of their goals in terms of fostering peace and cultural protection. However, in essence, that is a charitable function if you look at it in an absolute sense. And my point was rather about the absurdity of an EU city turning to the UN for help as a result of the EU’s attempts to allegedly not damage the perfume industry. Even if Grasse did obtain UNESCO World Heritage status, how will that really help the businesses within? Cultural protection is not business protection. And UNESCO cannot confer the latter if the perfume houses have a substantially reduced need for the business products.

What is key in your comment is your point about reframing the discussion. I think you’re absolutely right and that it is important. You’re also absolutely right about the slanted panel of “experts” that is skewing the picture, right down to the doctors indifferent to (or oblivious of) the larger picture. But if you really think about the details of what is involved, how could cultural protection be done? Giving Chanel No. 5 protected status as the olfactory equivalent of the Eiffel Tower? Well, where then does one draw the line? What perfumes make the cut, and which ones don’t? More importantly, who is to judge? It could end up being so arbitrary, not to mention being subject to highly subjective personal standards? Judge but also executioner.

So, on a practical level, conferring “cultural heritage” protected status on an individual perfume or lot of perfumes wouldn’t work, in my personal opinion. By the same practical, detailed standards, how can one give a blanket “protected for heritage reasons” label onto an entire industry? I mean, what are the specifics involved? Okay, say we have the lavender fields in Grasse protected, and the city itself. Say we also cover the orange growers and those who help with bergamot.

What then? Would the specifics of perfume production get blanket protection too? I can’t see that happening in reality. Grasse getting the same protection as the Taj Mahal and the Great Wall of China in terms of its buildings and city, yes. But I don’t see “cultural protection” of an entire business industry being something a bureaucrat in Brussels would be willing to suggest lest he be laughed out of the building. You can almost see the Champagne industry stepping forward to claim protection as a cultural icon, and could even go so far as to say that their business shouldn’t be regulated at all then. Then the car manufacturers could sue too, then the fashion makers would say, “Well, why not us? If you’re protecting perfume and alcohol, why not us?” Where would it end? And what would the EU have to do or, more importantly, be blocked from doing in terms of basic regulation if an entire industry was singled out for unique protection as a cultural icon?

It seems neither feasible, nor practical or realistic, imo, not when you look at the details. But what IS feasible are all the solutions that the EU is so obviously disregarding. At the end of the day, the solutions is incredibly simple: warning labels. All this massive fuss could be avoided by the same warning labels they put on cigarettes, on peanuts, and even on the Great Wall of China (by UNESCO) warning of danger of falling bricks or injury.

All so simple, to save so many people from grief, not to mention economic hardship.

Dearest Kafka
So much of interest, as I knew there would be, in your response.
The first and fascinating point, and I think one of perspective is the notion that ‘fostering peace and cultural protection’ is essentially a charitable function. Of course the arts are essentially charitably funded in the US, especially since the NEA has been effectively crippled and starved of resources. However that is manifestly not the case in Europe where culture is very much a matter for the state as well as philanthropy. Most European countries, even old Philistine Britain, have senior ministers for cultural affairs, in France it is regarded as one of the most powerful offices within government.
Nothing illustrates this gulf of understanding so much as the fact that the US had its voting rights in UNESCO suspended late last year, the latest sad chapter in a long and troubled relationship.
This may seem like scoring points, it’s not meant to be. I highlight the close ties between government and art out to indicate that culture is integral to life in Europe, not in the awful superior way in which is often claimed for moral value by some, but in hard economic terms. We are an old continent and much of what we have to sell to the rest of the world is based on our heritage, learning and history. That applies from universities to tourism, fashion to film, opera to advertising, fine wine to perfume.
There is an economic imperative in including high culture in high government which simply does not apply to the US or some developing parts of Asia in the same way.
Wine, indeed, may form a good case study and practical example, it’s production, promotion and sale is protected and regulated by a complex assortment of measures some cultural some economic.
Using France as a case in point again, we have a range of economic farming subsidies under the Common Agricultural Policy, regulation via the ‘Apellation d’Origine’ regime, promotion via the state as well as collectives of producers and cultural protection of some of the locations of production. The Loire Valley and St Emilion already enjoy World Heritage Site status, the vineyards des côtes de Nuits et de Beaune and yes, you’ve guessed it, Champagne, are on the short list to receive such status.
It may seem impractical from a free market standpoint that such a over-complicated nexus of cultural, social and economic intervention could be used to support an industry parts of which are mass market and profitable, parts steadfastly uneconomic and esoteric but that is precisely what happens in viticulture.
As such I don’t think it’s fanciful to suggest that a similar structure could be used to protect, stimulate and promote perfume.
Yes, of course, simple labelling is common sense but the straightforward fact is that argument is lost for now. Full stop. It’s over.
Procrastination, prevarication and duplicity have done for a quick fix, no matter how logical.
Only a more informed, intelligent and complex rear guard action that demonstrates an understanding of intra-national institutions and their workings can hope to rescue a very bad position.
Stamping our feet and wishing for something we’re not going to get is pointless.
This might sound harsh, but it’s only because I care about perfume so much, have an understanding of how these things work politically from past experience and am more than a little frustrated with constant cris de coeur that lead no wear that I allow my exasperation to show through.
Yours ever
The Perfumed Dandy

I laughed so much at this for the simple reason that you’re absolutely right: there is a massive difference in where we’re both coming from on the “charitable” vs. “culture/heritage” issue, and I’ve been impacted by living in America for far too long. It’s sadly funny and triste at how my views have been impacted by the conservativism of this country when it comes to cultural issues. America is more conservative as a whole than Europe, but the arts in specific have been treated very unkindly and differently here. It really IS a case of “charity” if anyone does anything protective or supportive to the arts. LOL. Has been for years, but in today’s Tea Party influenced government, the thought of the State (or any political group with power) caring about something cultural — never mind spending actual money to help it — is really laughable.

You are so right about the different sort of both cultural and economic imperatives that fuel the European focus. It’s hard for me to relate to in a way, after so much time in a country that is all about the Free-Market and economic bottom line. You very astutely noted that political impact on my perception and thoughts when it comes to this issue. I find that a rather sad statement of how this country has changed me, how the politics here has turned me cynical. Well, even more cynical than I already was. 😦 But thank you for a truly illuminating, fascinating, and ultimately positive perspective, my darling Beau.

I do hope that you’re right about Europeans being much more willing to treat cultural treasures with the sort of protection that they warrant because of how it would economically benefit them in the long run. If someone is going to apply the viticultural model used with the French appelations/vineyards, I hope they bloody well do it soon, because I can’t see the EU backtracking on the restrictions once they are officially passed. 😦

I don’t need to think it through anymore – this response says it all. Brilliantly and astutely written. As a transplanted Brit who has live in the colonies 😉 for nearly 30 years I forget how culturally entrenched my birth-countrymen are. Kafka says it very well below – it is SO SO easy to become cynical living in the US and I am SO SO guilty of that. At the end of the day here it really is all about the mighty dollar, which is why, I think, I have had such a hard time figuring out this perfume fiasco – my initial automatic thought was that it must be about money and to follow the money trail as I mentioned before. I’d assumed that money was at the root of this particular evil and that the war can be waged and won by just throwing more money at it (Guerlain et al I was looking at you). However we’re talking about Europe, a completely different beast when all is said and done. Cultural and historical preservation/conservation is in the DNA – as you say not just to take the moral high road, but the economic high road.
If we’re truly beyond choosing the simplest solution of warning labels etc, then perhaps this stance *is* the way to go.

God, it’s terrible how cynical one becomes here, how focused on the “bottom line,” and on the politics of things, as well as how money rules it all. I’m sorry to hear that you’ve been similarly transformed. It’s rather depressing, isn’t it? Still, I don’t want to get into politics, let alone American politics, as this is really not the place for it. More importantly, it never — ever — ends well, so I’ll just shut up about what I think regarding the current state of affairs (not even just here, but in terms of the individual as a whole against corporate interests in today’s world).

On a more positive note, let’s just hope some cultural minister or another will share The Perfume Dandy’s ideas. Actually, perhaps we should just beg HIM to run for EU office? 😀 Not sure the poor chap deserves that burden, but he certainly would have the perfect platform on which to run already: De-Regulation and Cultural Preservation. lol Plus, I think he’d be rather brilliant at it, as he is in everything he does.

Hi Kafka. This discussion could go on for a very long time without any changes being made to the mindset in Brussels. What is needed is a concerted effort to get the message out to the common man and woman across the EU about the absurdity of this proposed legislation and what it will mean to them – less choice to decide what we can and cannot do as individuals in a democratic society. This discussion around perfume is about freedom of choice being demolished by Brussels because of a potential 3% of the population. That means, statistically, of course that at least 97% of people are being deprived of their right to something. That is clearly undemocratic. Everyone who has an interest in preserving the status quo should be using every website, Google+ , Twitter, Pinterest, Instagram, LinkedIn and Facebook account and every senior Commission email address known, to petition against their plans. Bombard the Commission with the message that enough is enough! Someone needs to come up with a catchy marketing phrase that everyone can adopt and which will reinforce the message across all media and appeal most to the common man and woman on the street who buy the products. Then let’s talk more about real vs synthetic perfumes.

Well, grassroots movements have been known to work before, though very infrequently. I’m dubious about how petitions would impact this situation though, given the completely divergent, but powerful, number of groups involved here — many with very different agendas. One could target Brussels, but the problem is that there are so many varied groups really pushing this, from big aromachemical giants to health lobbyists and others. Regardless, there is nothing to be lost by trying.

Exactly! Occams Razor or KISS! For pity sake, make it up to the consumer as to whether we buy or not. Why should – yet again – the majority be affected by the minority?? And what a load of cobblers : “may be allergic or may become allergic to them” – that’s like saying I shouldn’t ever eat baked beans again incase they might make me fart! Sorry, but the stupidity of this makes my blood boil. I resent not being able to buy something because the powers that be deem me too stupid to read a warning label, and so alter the product so I won’t have to be saddled with that terrible responsibility. This is another example of Big Brother and I hate it. And how is *my* (non-allergic) wearing of a perfume going to affect another (supposedly allergic) person?? And I don’t mean drenching myself in vats of the current Britney monstrosity… So because a tiny percentage of the community may — MAY — be allergic to certain ingredients, I who am not, have to pay the price. And what about soaps, body washes, hair products etc that use such natural ingredients? Are they all going to be pulled off the market too? I can only imagine what would happen if menthol or menthone were to come under the same microscope: peppermint oil which contains these can cause irritation to the skin and mucous membranes – will the toothpaste industry be in danger of collapse if so?
Slap a sticker on the bottle – heck, plaster a skull and cross bones in it for all I care, but give me the choice !!!

I think you make a good suggestion here. Shift the paradigm from consumer protection v industry interest (we lose, as you say) to one of concrete culture preservation v abstract (spurious as you say) health claims and the debate becomes – well – far more debatable and open ended, although I’m not sure if it could be won. As Kafka follows up below, set such a precedent and where does it end? My answer to that I suppose, would be “why should it end anywhere if it is beneficial?” Its hard to tell if it would be a slippery slope but leading to a positive outcome or a good theory but impractical in reality. More thought needed on my behalf.

Can we do anything?All of us,the perfume lovers,can we put our names under a letter addressed to the appropriate authorities in Brussels?There are at least 3000 perfume lovers on Facebook.There must be something we can do.I am definitely not smart enough or eloquent enough but I am ready to support people that are and which are fighting our corner.

I think there is nothing wrong with trying and petitioning, but it’s really going to be up to one’s individual philosophy in thinking whether it works or not. I happen to be too cynical to think it will do much good. This is not akin to targeting one company, like a McDonalds or something, but a State entity driven by a wide number of very different, powerful groups with competing agendas (unified by their uniform, negative goal of forever changing perfume as we know it). I personally doubt boycotts would work, and I think Brussels would stick a petition in the rubbish bin, even if it had 100,000 signatures.

Again, though, there is nothing wrong with trying, especially if one can get the media interested enough to make the situation widespread and drive interest. So, if you or others want to do a petition, there are easy online ways of doing it that would permit the petition to go viral or get international signatures. It’s certainly worth the effort. 🙂

I am wondering the same thing as Ana. Can the people have a voice in all of this ridiculous and wrongly placed regulation??? The things that governments decide to act on is often so foolhardy and bizarre, completely missing the point of actually assisting in change that will really benefit the health of the people. This kind of bullshit makes me growl. Sorry for swearing.

Thanks for doing the research on this subject, Kafka. Infuriating, but we need to know.

As I wrote to Ana, I think there is nothing wrong with trying via petitions and the like. Whether or not you expect something to actually come of it will probably depend on one’s individual philosophy or expectations about grassroots movements being able to effect government change. I happen to be a cynic, at least when it comes to political entities and financial matters. For me, personally, this is not analogous to an Arab Spring situation where a grassroots movement would have a chance of resulting in a substantial change, but, again, I’m a cynic.

II’m with Ana and Tora.
I get extremely frustrated reading about these regulations (especially as no one seems to have banned peanuts which cause more allergies) but what I want to know is what exactly can we do? There must be something we can do. Gather money and employ a good lawyer on the perfume behalf?

The problem is that the other side has a plethora of good lawyers and money. And since when does a massive governing, political body really care about what the peons in the masses really think, especially when it comes to some economic matter? The fact that this has been framed as a “public safety” issue renders it even more difficult, because it’s not analogous to moving for civil rights changes or overthrowing an oppressive political goverment à la Arab Spring. A lot of companies and groups would be extremely wary of being labelled as opposing a “public health” matter.

Perhaps I’m too cynical. As I wrote to Ana and Tora, there is certainly no harm in trying to petition or start a grass roots movement.

Laurie Erickson from Sonoma Scent Studio also posted about this issue on her blog, Perfume in Progress, on 2/13. It’s all over the blogosphere, but as she is a perfumer based in the US who uses both natural and synthetic ingredients, I hope we will hear more from her as to what her concerns are.

I find this truly baffling. Here in the US the practice of aromatherapy got hit very hard by making claims that essential oils have therapeutic (read “any”) effects. One of the original, well-known and respected suppliers, Aroma Vera, was basically wiped out by the NCAHF in 2000, and most of the companies supplying essential oils to the public keep a very low profile at present. So here in the US, we’re claiming that these ingredients have no effect. In fact, we can now purchase Mandy Aftel’s Chef Essences and ingest essential oils.

It will be very interesting to see how this plays out. Will the US maintain its position and allow the continued use of what the EU restricts? Thinking of the ramifications for the entire industry, literally from the ground up, is mind-blowing.

Very interesting about the US aromatherapy industry and Aroma Vera. Very interesting indeed. You’re right, there seems to be a huge difference in how the two government entities are handling things or how they’ve framed the discussion. The fact that the EU is presenting all this as a “public safety” matter makes it even more tricky for some companies to come out publicly against it. Would a politician want to be seen as fighting for Chanel No. 5 over the “public health”? Doubtful. Think of what a field day his opponents and enemies would have with that! It would be seen as a frivolous, superficial concern that benefits companies over the public’s well-being.

In light of all that, the fact that the US is basically implying that none of these essential oils have any therapeutic value could be taken in ways: they don’t add any benefit; they don’t do anything; or they don’t help. That last one might be skewed or twisted into “they are negative” instead of just “they are neutral.”

I don’t know, at this point, all the various, twisting, morphing ramifications are making my head hurt. I think I need more sleep. lol

If the justification for these proposed regulations is ostensibly medical in nature,then why are there NO medical organizations showing any interest in or support to them? The analysis is faulty at its very root. The underlying problem that the regulations are supposedly designed to fix is mostly a fabrication.

Even if there is medical justification for changes, that does not change the fundamental point that this is a totally ridiculous idea for ‘potentially’ only 3% of the population and a total disregard for the 97% who can make their own mind up about what to use, consume etc. It’s undemocratic. In answer to others who have asked what could be done: leave the legal matters for the industry majors to pay for, everyone else can post – as I have been doing – this blog on every social media site that will gain major exposure. People Power at its roots.

Please see my expanded note below. If, indeed, 3% of a population were seriously at risk of some health danger, that could still add up to tens or hundreds of thousands of people, and governments would indeed have a responsibility to act to protect the minority even if the majority didn’t like it. That’s part of the reason we have a Bill of Rights in the U.S.A., to protect the minorities from the majority when necessary. But we’re not talking about numbers of people anywhere close to that. In the history of humanity, there have been 2 reported cases of anaphylaxis from perfume ever. Both were from very atypical uses, not routine application. The world doesn’t need effective bans when the issue at hand is migraines and skin rashes; warning labels would be the obvious appropriate and balanced approach.

Well, there may be medical organisations that have shown interest or supported them, but I personally haven’t read about any being mentioned in the international media. That doesn’t mean that they don’t exist or aren’t covered by more national media groups within countries like France or Brussels.

That said, I do agree with your points. The fact that these regulations are intended to be future-preventative — i.e., protect 1%-3% of the population who MAY have the mere POTENTIAL to experience an allergy — says volumes about the underlying analysis.

I think The Perfume Dandy raised an excellent point about how the Commission is listening to a very skewed panel, which includes doctors who have little interest in the larger picture. The doctors are talking about all this as an abstraction and about what may happen, but haven’t grounded their conclusions in a narrative that considers non-medical hypotheticals and real-world issues.

Perhaps there are groups or individuals on the SCCS advisory committee who *are* presenting the other side but, if so, they’re obviously being ignored.

I was afraid this would happen, and it makes me very angry and frustrated. We sell alcohol, tobacco and potentially deadly medications to the general public over the counter, and all they need are warning labels. Does the EU REALLY have nothing better to do? I simply do not understand the reasoning here, unless it really is a push by the aroma chemical makers in order to sell more of their synthetics – but as you pointed out, the companies like LVMH, who have a lot more market clout, are in no way in favor of the changes. Just put labels on everything and leave perfume alone!

Hi Flora, welcome to the blog. I’m with you in not understanding the reasoning and logic here. For me, that is one of the most frustrating things about the situation because it’s too difficult for me to comprehend the basics. I think that’s probably inevitable for any situation that is so complex, driven by so many competing groups with widely divergent agendas, but the sheer lack of common sense and, again, LOGIC, confounds me.

Take the money issue. I can’t figure out the money trail in all this. Whatever profit certain groups like Givaudan or IFF may gain is far outweighed (it would seem to me) by the financial losses by other, equally big, or even bigger groups. If one is weighing the financial scales, you would think they would consider the hundreds of millions in combined losses by everyone from LVMH, Chanel, Robertet, all the companies who have to reformulate those 9,000+ fragrances, the natural producers, the farmers, the European sellers who are losing sales (and therefore, not contributing VAT to the EU), and more.

It’s the tangled money trail that makes this even harder for me to understand, because I can’t even chalk up the illogical actions to a simple explanation of “Oh, it’s all about money.”

My concern is that companies working outside the EU would still not be able to sell these products within the EU, as I understand it. Also, producers of raw materials within the EU wouldn’t be able to produce their goods.

My greater concern, however, is for the truly niche perfumers working on their own WITHIN the EU like Andy Tauer, Neela Vermeire, etc. They are thoroughly screwed, and they don’t have the massive financial capital of LVMH to easily get through all the changes, restrictions, additional reformulations, testings, etc. All these small, truly creative, innovative artists who are pushing the envelope or trying something new are the ones who will suffer the most, and that means that the originality of perfumery is being even further stifled in favour of generic, synthetic creations put out by Estee Lauder’s various brands (Tom Ford, for example) and filled with even more of Givaudan’s synths. (Tom Ford’s many “noses” are often from Givaudan’s stable of perfumers to begin with.)

Vintage perfumery is already gone, the classical tradition is practically gone, and now the future of original perfumery is seriously in jeopardy as well. Welcome to the global conglomeracy of perfume put out by the super-wealthy companies focusing on a bottom line profit through generic fragrances with cheaper ingredients and a higher profit margin.

Anyone who wants to sell in the EU will have to change their formulas, artisanal brands or Amouage. It is highly impractical for any perfume house — even one as wealthy as Amouage — to have two version of the same item, one “EU compliant” and one “non-EU compliant” for sale outside of Europe. So, unfortunately, everyone ends up having to follow the manditory EU law if they want to sell in the EU. What many small, artisanal American companies are doing are simply avoiding the entire market there. It may hurt them not to be able to sell to European customers, but they refuse to compromise their artistic vision and integrity. Larger companies like LVMH’s Guerlain don’t have that option of dismissing EU customers as they are driven by shareholder considerations. Even privately-held companies can’t afford to ignore such a massive market.

The greater problem is for the small, artisanal and truly niche companies WITHIN the EU, like Andy Tauer, Vero Profumo, Neela Vermeire, Viktoria Minya and the like. They are totally and completely screwed. They lack the massive pockets of LVMH or Chanel, they can’t move to a whole new continent, and they have to spend even more out of their own pocket to amend their fragrances, in addition to the huge costs they already bear for IFRA Compliance Testing, labeling, etc.

Perhaps people would like to contact IFRA directly with any questions they may have. Their Swiss HQ and Brussels phone numbers are here: http://www.ifraorg.org/en-us/contact#.Uv_HRZwgGSM. Perhaps IFRA could clarify their position a little more given everyone’s concern…?

Do you really think IFRA — financed by IFF, Givaudan and Symrise, and led by executives who came from companies like Unilever and Coty — will really give a damn about people’s concerns? You’ve seen their public statements already and how they have framed themselves. They’re highly unlikely to respond in any different way beyond giving lipservice to the party line, and talk about how they’re here to protect the perfumers as well as the public safety.

It was not meant seriously as a kind of a ‘excuse me, could I politely ask you for your opinion about….’ type of exchange Kafka. However, a continual PR campaign including very public messages on LinkedIn might embarrass the likes of IFRA, Givaudan, Symrise, IFF, and my ‘mate’ Buddy from Coty, as he once referred to me in an email exchange. If there’s a PR professional reading this please advise us all how to formulate such a message for posting on LinkedIn, and an appropriate message of the right length and/or comments + photo to use on other social media such as Twitter, Facebook, Pinterest, Instagram…many thanks!

I find the alleged concern for consumer safety and public health simply unbelievable. My skin is so sensitive that shower gel and fabric softener are out of the question for me, and at least 90% of the lotions on the shelves of my local drugstores contain at least one ingredient that either gives me a rash or makes me break out. Yet I have never gotten a rash from perfume. No one has ever, to my knowledge, proposed banning isopropyl myristate, which is terrible for the skin and gives me a painful, scabby rash. Efforts to ban artificial dyes like yellow 5 and yellow 11, which are known to cause problems for many, haven’t gotten anywhere in the US. I bet L’oreal, Estée Lauder, Unilever, etc. would protest vociferously against banning many ingredients that cause actual harm to more than 1% of the populace. Many drugs that can cause severe allergic reactions (Prozac’s allergic reaction rate is more than 1%, and penicillin’s is even higher, to name only those that have affected my immediate family) remain on the market. The idea that perfume should be more tightly regulated than food, drugs, and toiletries is obviously ridiculous. Maybe the ultimate goal of the fragrant chemical companies is actually to do away with all consumer protections, and promote the idea that plant-based substances are more dangerous than petrochemicals. (After all, why should novel chemical concoctions be tested for safety if lavender is just as bad?) Something about this whole thing just smells rotten, if you’ll pardon the pun.

An excellent point about prescription drugs, Laurels. And even if they remain on the market in spite of the noted potential reactions, they come with that loooooong listing of side effects when you pick them up at the pharmacy, which you can read and then decide if the risk is worth taking them or not. I’ve previously been prescribed something, found out about the side effects and said no. Give us, the buyer, the same choice as with medications, with cigarettes – we can (gasp) handle the responsibility of the choice! As you say, there’s a bad smell to this and I cant quite figure out where it comes from exactly. The whole thing doesn’t quite make sense…

You’re right in noting the danger of medications, as well as the unregulated body wash issue. You know, my sister is massively allergic to perfume, though she wasn’t in her younger years. She’s also allergic to parabens, gets a bad reaction from some medications and a ton of different ingredients in makeup. Even certain food products don’t do well with her system. She can get a massive headache from perfume even on another person from a small distance, but she’s never asked me not to wear it. (I merely reduce the amount, or skip it entirely, when I’m around her.) The thing is, my sister doesn’t need to be told not to wear perfume or to avoid beauty products with other problematic ingredients. She simply just does it, like any sane adult would. And I highly doubt similar people in the EU need to be told to avoid wearing perfume. They wouldn’t even need a label, either.

In many ways, the EU seems to be taking future action against a mere hypothetical potential: that 1%-3% of its population MAY, possibly, perhaps, once in a blue moon, get a skin rash or headache from perfume. POSSIBLY. Maybe. Well, that is simply insane, particularly given your comparison to prescription medications which are KNOWN to have a wide variety of possible side-effects. In some ways, the future-hypothetical premise for all this is the most ridiculous part of all.

The best solution is to simply add a notice on the perfumes ingrediens that can cause allergic reactions. We already have to list the allergic ingrediens. Eugenol*, Citral*, Cumarin*…. *may cause allergic reaction.

99-97% will not have any allergic reaction. The intention of IFRA (sponsored by Givaudan, Symrise ect.) is clearly to make them sell more Synthetics. There is no doubt. This is Prohibitionism and Lobbying.

I really hope they will found civilized and democratic solution on this.

I love the “Eiffel Tower” analogy! (and all the other puns!)
No, seriously I am well pi**** off with all this. First they are stopping
us sending perfume abroad and now they want to stop us buying
any of it that smells any good. If only they would be as draconian about
all the toxins in cigarettes and ban them instead. Perfume has never harmed me
and I have drowned in the stuff for the past 35 years.
Maybe I am getting old, but it seems everything has to be monitored and regulated
within an inch of its life these days (teachers, hospitals, taking photographs, Royal
Mail etc.etc.) Rant over, but let’s try and do something about this.

LOL at your mail comment. You’re obviously in the UK with its particular brand of fascistic shipping issues concerning perfumery. (X-raying packages? Seriously??!! Bah!) Last time I checked, British Air didn’t ban alcohol on flight or Duty-Free perfume purchases, so, yes, your country does seem to be taking the Nanny State regulations quite far.

Like you, I’ve been wearing fragrances for over 35 years, and it certainly hasn’t harmed me either.

I admit that I didn’t read through all of the comments thoroughly, but it seems that the question of “why?” remains completely unanswered. No one is going to clearly benefit financially, and probably the regulations will harm many EU industries large and small.
Cynic that I am, my guess about the motives underlying this type of micromanagement by the EU is that it is mega-bureaucracy’s way of instilling a feeling of learned helplessness in their subjects. I see this tactic used all the time by the administration of the university where I work, by the local, state, and federal governments, and by corporations that do not want to provide any sort of service to their customers.
A populace trained in learned helplessness will eventually stop complaining about anything, and will swallow any bullshit piled upon them, no matter how ridiculous (in the beginning) or oppressive and harmful (in the end).

Hello, Dr. Covey, and welcome to the blog. I smiled at your comment. Not only because I’m a fellow cynic, but because it reminded me of the totalitarian approach to control. Hannah Arendt’s Origins of Totalitarianism and life under the Iron Curtain came to mind, as a similar principle was at play. I don’t know if the EU is acting for the same underlying philosophical reasons, but there is definitely a micro-managing ethos applicable to most large institutions which feels a little similar in terms of how they seek to impose control from the top down. Either way, you’re right that no-one seems to have come up with a truly logical, rational answer thus far to explain precisely WHY all of this is happening to begin with.

You don’t sell to the EU, do you? It must be a relief to have that greater artistic freedom and individual control.

Most people who may be allergic to perfumes or specific scent chemicals have a skin reaction which is not dangerous or life-threatening in any way. A brief review of medical literature reveals only two, yes that is TWO, reported cases of anaphylaxis, which is the severe, life-threatening kind of allergic reaction. One occurred in a health care worker when a patient sprayed her directly in the face with 3 sprays of perfume (I’m completely serious, look it up–Lessenger JE. Occupational acute anaphylactic reaction to assault by perfume spray in the face. J Am Board Fam Pract. 2001;14:137-40). The other occurred when a mother sprayed her 2-month infant in the face with cologne. Neither of these would be considered by anyone to be a customary use of fragrance. Incidentally, in the case of the infant, the cologne contained menthol which was the ingredient the authors suspected to have been the main factor in triggering this response. Is menthol even on the list of ingredients of concern? Should any chemical be regulated if, in the recorded history of humanity, there have been but 2 cases recorded of any anaphylactic reaction and in both cases the perfume was being misused? 3 percent of a population is not a trivial number and would be potentially worthy of public health initiatives if that population were at risk. 2 cases out of the billions and billions of people in the world? Seriously? What a ridiculous waste of time and effort. This is why no reputable major health organizations are militating for any of these regulations. Banning a chemical because some people in the vicinity might get a migraine or the person applying it might get a rash makes little sense.

Colin, I love all the specialized information. I can’t thank you enough, as I find it incredibly informative and it really adds more to the overall picture. Keep it coming, and thank you for coming out of lurkerdom to share your invaluable knowledge.

Noooooooooooo, don’t lurk! Even apart from the medical or EU perfume issues, don’t lurk! Perfume is always more fun when shared. Plus, I enjoy the different perspective that you bring to things and, more to the point, I love people with analytical minds who focus on details and facts. Perhaps you will take my request under advisement? 😉

Excellent points here. I’ve been thinking about this a lot since I read the first posts and as mentioned, have felt like there is a piece missing. I don’t think its simply about the money – as Kafka so astutely pointed out, the money trail is so convoluted and there is no clear “winner” here, although I can see that the synth manufacturers would make a bundle, but aren’t they directly connected to the perfumers?? Anyhoo, moving on to the reason given by the SCCS etc al, as many have pointed out and as you back up with your very interesting stats, the health reasons don’t hold much water in the argument either. The only way this whole equation possibly “works” for me is if that piece which I feel is missing is labeled “UNLESS.” What I mean is that the EU and cronies are going to say “this is what we will do (regulations) UNLESS…” – what the unless is I don’t know, but THAT is where I think the $$$ might rear its ugly head. I just cant help feel that we haven’t yet heard the entire scenario – as we all agree, if this IS the entire scenario it has as much credibility as a chocolate teapot….

Why is this happening? Because few of the big-business interests aromachemicals have set in motion a mechanism that infernal now out of control. We must have recourse to the law, the European Courts AGAINST these interests. It is possible that alcohol and cigarettes are free and oakmoss and sandalwood are prohibited? We must take them to court. And the great battles to organize boycotts and only buy vintage perfumes. So they will understand.

I read this article, and the comments yesterday. Got even angrier than I already was (background of that at the end of my comment). I posted a link to your article on my Facebook page and website, and linked it to Twitter, all in fiery fury. I thought I’d stay in lurkerdom until my anger would settle a bit (a year, maybe?)
Slept over it.
A friendly Facebook-fan commented with this blogpost : http://graindemusc.blogspot.nl/ (“The only thing that will change is the number of substances that must be labeled: 89 instead of the current 26.”).
The bottom-line is still that the direction is a quite negative one for natural perfumery – slowly but surely the EU legislation is squeezing the playground of NATURAL perfumery smaller, forcing those who want to stay in the perfume business to buy synthetic fragrances (since more and more natural fragrances = essential oils are being restricted because 1-3% of the population has ever had an allergic reaction to them).
The way I see it is that the companies that MAKE the synthetic fragrances are behind the allergen advisory panel (financing it). Correct me if I’m wrong.

Many of you have been raising the idea of making a public outcry. A great platform to do that is Avaaz.org , it’s international and powerful.

And now to why I was angry already: I awakened to the current EU-legislation, requiring laboratory tests etc. for all cosmetic products a bit ‘too late’. As I’m a good citizen and don’t like to get fined I closed my webshop (ninasnature.com) immediately in order to get my documents done.
In almost 2 months I’ve found out that…
1. The laboratory tests for natural perfumery are very expensive.
2. Putting together all the needed information – no, FINDING all the needed information is time consuming and sometimes downright impossible (my main supplier refuses to send me the needed safety documents for the essential oils, saying I’m “too small”. Huh?!)
3. It is such a complex legislation that I’m wondering how the decision makers at EU headquarters imagined small business owners could comply. (I know, they didn’t think about it.)

Currently I’m looking for a free-lance toxicologist to help me out, while I’m wondering if there IS a way out. If this is the direction of things, it’s a dead-end road anyway…

Unless we cry out, as a community of natural perfume lovers, suppliers and perfumers.

I will be offline the coming 9 days, but am sure to check in again on the 3rd of March.

Thank you for sharing your thoughts and experiences, Nina’s Nature. I hope you find a good toxicologist to assist you. As for Avaaz.org, it’s one of many petition platforms or sites that people could use. It certainly won’t hurt to create a global petition for everyone to get behind, though I personally am too cynical to think it would do much good in this case. Still, there is no harm in trying, so perhaps someone will heed your call. 🙂 The existing EU restrictions are bad enough, without all the additional ones that may come of the new 2014 proposals. Even if it is a mere labeling issue for some things, the logic behind the ENTIRE regulation venture is simply not there, imo, and never has been, given all the other things which are unregulated. Plus, there is the issue of an unsound medical foundation to all this regulation to begin with. In any event, maybe a petition will work. All the best to you in your personal ventures for Nina’s Nature webshop.

Dear, dearest Kafkaesque,
Thank you for your kind words! I’m afraid I share your cynicism, but will consider (lots) during my 9-day retreat.
I want to take this opportunity to express my gratitude towards your blog (such a small word for such a powerful site) – it is quite special, honest, thoughtful and thorough. Wishing you lots of inspiration and precious moments, keep up the good work!

At the risk of increasing your blood pressure, I would to draw your attention to another site. Colognoisseur, the new blog from Mark Behnke, the former Managing Editor of CaFleureBon. Mr. Behnke has a chemistry background, and he discusses the total LACK of any sound scientific basis for these regulations. Specifically, it all comes down to one single test, with a mere 25 subjects, and no controls. http://colognoisseur.com/editorial-90-days-til-the-end-of-perfume/

It’s enough to make one’s rage utterly uncontrollable because, whatever ends up having with the full scope of these regulations beyond the mere oakmoss issue, the bottom line is that all of this was empirically dubious to begin with.

I was actually planning on updating my review to reflect Mr. Behnke’s points, but I’ve been too busy. (I did it now though.) Still, it’s something that everyone should look at, imo.

Dear Kafkaesque,
Ofcourse you may 🙂 .
I will save reading the article for when I return, for all reasons imaginable.
At the midst of all the madness I am happy to find some sense in all this – that is, that I’m not the only one finding the whole situation utterly illogical. Sharing and reading puts it all into perspective. I will get back to it upon my return!

Nina,
i think It is not true that they have not thought about a “little” producers.
Indeed, precisely because we have thought have made life more difficult . I’ll explain how I see it : the fight was beginning to replace the natural oil with chemicals. But along the way they realized they had against the big houses . Then they decided to keep her good making life more difficult for the little ones, who are their potential competitors.At this point,this is an alliance between Chem/big against natur/little. Hi

Dear Geco,
Perhaps you’re right. But for the chem/big (possibly) to think nature/little is a competitor of them is far-fetched since the customers are very different – the niche is different for both. Unless the chem/big also thinks that natural perfume smells far better and they’re actually afraid of losing customers…! I think it comes down to plain cold cash: make synthetics the only legal option and the money comes to their pocket.
What about health?
What about variety?
What about the environment?
What about the income and pleasure in working of so many people?
I really need that retreat now. See you later!

Dear Nina, i think 4 things.
1) Big aromachem companies want to replace the natural oils to sell their synthetic creations.
2) The great perfume houses want them to be few producers who can make perfumes.
3) The rules IFRA and EU help these results.
4) We do NOT have to remain indifferent to such things. We have to stop them.
Good holiday to you,
geco

How to submit your contribution
Any comments should be sent with the reference: ‘Fragrance allergens – Public Consultation’ by post or e-mail by 14th May 2014 at the latest to:
European Commission
Directorate General Health and Consumers
Unit B/2, Health Technology and Cosmetics,
Office DM24 02/082
B-1049 Brussels,
Belgium
E-mail: sanco-cosmetics-and-medical-devices@ec.europa.eu

I am newer to perfumery, specifically natural perfumery, though a long time fan of all perfumes. I have written to the EU as suggested and would love to be involved in further efforts if anyone has any suggestions. Perhaps a form letter folks could share? I am not experienced with this sort of thing but would love to be involved.

Thanks so much for sharing all of this information, devastating though it is.